CFM17285 - Repos: taxation
This guidance describes the treatment of repos for income tax
and capital gains tax purposes, and for corporation tax purposes
where the original owner transfers the securities to the interim
holder before 1 October 2007
Accrued income scheme
ITA07/654 excludes transfers of securities in a repo from the
scope of the accrued income scheme. This rule is only relevant to
non-corporates.
The accrued income scheme is not disapplied in relation to
post 8 April 2003 transactions where:
- ICTA88/s730A is prevented from applying by
virtue of section 730A(8) or;
- For 2007-08 onwards, ITA07/S608 prevents
ITA07/S607 from applying – see
CFM17225.
